Dec. 2. 20M ATMOS ENERGY No.1930 P. 2


energy

Vice President, Technical Services
Mid-{Tex DMsion

December 2, 2014

Ms. Polly McDanald

Director, Safety Division
Railroad Commission of Texas
Post Of?ce Box 12967

Austin, Texas 7 8711-2967

Safety Evaluation No. 20133664
Inspection Package 108591
Richland Hills Unit

Dear Ms. McDonald:

Attached is Atmos Energy ?m Mid?Tex Division?s response to the alleged violations in' the
referenced safety evaluation. The attached listing documents the actions taken.

If ?lrther information is needed or if you have any questions concerning the atoms taken, please
do not hesitate to contact me.

Yours truly,

mew

Jeffrey S. Knights

Attachment

Atmos Energy Carpet-5mm

P. O. Box 2.23705

Dallas, TX 7522243705

214.205.2701 214-206-2126 jcf?knights?amtosrsnergy.com

Dec.

20% ATMOS ENERGY No.1930 

ATMOS ENERGY CORPORATION
DIVISION
Ransom) COMMISSION SAFETY
EVALUATION Nos 20133664
PACKAGE NO. 103591
RICHLAND HILLS UNIT

North Riehland Hills S. E. No. 20133664

1.

Means Energy Mid?Tex currently assesses risk as outlined in our Distribution
Risk and Integrity Management Plan for the identi?cation, assessment, and
mitigation of threats that would increase risk to the integrity of the distribution
systems which complies with The requirements of 49 CFR Part 192?, Subpart P.
This approach incorporates a statistical risk evaluation methodology built 0n
leakage history data. Risk takes into account both the likelihood of failure and the .
consequence of failure. The plan focuses on eliminating the greatest relative risks
by assigning inspection and mitigative actions {according to the overall risk
evaluation. Because the threat identi?ed from poly~fusion joint installation does
not have a comparable risk to other Imown threats, no accelerated actions above
our existing prescriptive leak survey frequentiies are in place. A report generated
from our asset management system revealed that only 0.13% of the reported
MidTex leaks since 2008 have been identi?ed to involve butt-?ssion failures.
Annos Energy?s DIM plan is an evolving iterative process with new data being
continuously added and removed ?om the analysis. Each year, risks and threats
are rewevaluated. Should future data suggest that additional action be taken with
respect to poly joint failures, it will be addressed in the future assessment and
resulting mitigative measures.

Atmos Energy is in the process of scheduling laboratory analysis of the failed
joint to determine whether or not this contributed to the incident at 7916 Harwood
Rd. If deemed necessary, We will perform ?irther testing once this analysis is
complete. .

We have not been able to ?nd a written procedure for joining PE pipe from that
era. Discussions with members of our engineering department determined that it
was common to use manufacturer?s installation procedures for the type of ?ssion
work performed in this 1970?s timeframe.